Elements of Process Safety Management

Unexpected releases of toxic, reactive, or flammable liquids and gases in processes involving highly hazardous chemicals have been reported for many years. Incidents continue to occur in various industries that use highly hazardous chemicals which may be toxic, reactive, flammable, or explosive, or may exhibit a combination of these properties. Regardless of the industry that uses these highly hazardous chemicals, there is a potential for an accidental release any time they are not properly controlled. This, in turn, creates the possibility of disaster.

Recent major disasters include the 1984 Bhopal, India, incident resulting in more than 2,000 deaths; the October 1989 Phillips Petroleum Company, Pasadena, TX, incident resulting in 23 deaths and 132 injuries; the July 1990 BASF, Cincinnati, OH, incident resulting in 2 deaths, and the May 1991 IMC, Sterlington, LA, incident resulting in 8 deaths and 128 injuries.

Although these major disasters involving highly hazardous chemicals drew national attention to the potential for major catastrophes, the public record is replete with information concerning many other less notable releases of highly hazardous chemicals. Hazardous chemical releases continue to pose a significant threat to employees and provide impetus, internationally and nationally, for authorities to develop or consider developing legislation and regulations to eliminate or minimize the potential for such events.

PSM Elements

Specified minimum elements that the OSHA standard requires employers to do:

1. Develop and maintain written safety information identifying workplace chemical and process hazards, equipment used in the processes, and technology used in the processes;
2. Perform a workplace hazard assessment, including, as appropriate, identification of potential sources of accidental releases, identification of any previous release within the facility that had a potential for catastrophic consequences in the workplace, estimation of workplace effects of a range of releases, and estimation of the health and safety effects of such a range on employees;
3. Consult with employees and their representatives on the development and conduct of hazard assessments and the development of chemical accident prevention plans and provide access to these and other records required under the standard;
4. Establish a system to respond to the workplace hazard assessment findings, which shall address prevention, mitigation, and emergency responses;
5. Review periodically the workplace hazard assessment and response system;
6. Develop and implement written operating procedures for the chemical processes, including procedures for each operating phase, operating limitations, and safety and health considerations;
7. Provide written safety and operating information for employees and employee training in operating procedures, by emphasizing hazards and safe practices that must be developed and made available;
8. Ensure contractors and contract employees are provided with appropriate information and training;
9. Train and educate employees and contractors in emergency response procedures in a manner as comprehensive and effective as that required by the regulation promulgated pursuant to section 126(d) of the Superfund Amendments and Reauthorization Act;
10. Establish a quality assurance program to ensure that initial process-related equipment, maintenance materials, and spare parts are fabricated and installed consistent with design specifications;
11. Establish maintenance systems for critical process-related equipment, including written procedures, employee training, appropriate inspections, and testing of such equipment to ensure ongoing mechanical integrity;
12. Conduct pre-startup safety reviews of all newly installed or modified equipment;
13. Establish and implement written procedures managing change to process chemicals, technology, equipment and facilities, and
14. Investigate every incident that results in or could have resulted in a major accident in the workplace, with any findings to be reviewed by operating personnel and modifications made, if appropriate.

HOW THE PSM STANDARD WORKS

The standard mainly applies to manufacturing industries - particularly, those pertaining to chemicals, transportation equipment, and fabricated metal products. Other affected sectors include natural gas liquids; farm product warehousing; electric, gas, and sanitary services; and wholesale trade. It also applies to pyrotechnics and explosives manufacturers covered under other OSHA rules and has special provisions for contractors working in covered facilities.

In each industry, PSM applies to those companies that deal with any of more than 130 specific toxic and reactive chemicals in listed quantities; it also includes flammable liquids and gases in quantities of 10,000 pounds (4,535.9 Kg) or more.

Subject to the rules and procedures set forth in OSHA's Hazard Communication Standard [29 Code of Federal Regulations (CFR) 1926.59(i)(1) through 1926.59(i)(12)], employees and their designated representatives must be given access to trade secret information contained within the process hazard analysis and other documents required to be developed by the PSM standard.

The key provision of PSM is process hazard analysis - a careful review of what could go wrong and what safeguards must be implemented to prevent releases of hazardous chemicals. Covered employers must identify those processes that pose the greatest risks and begin evaluating those first. PHA's must be completed as soon as possible. PSM clarifies the responsibilities of employers and contractors involved in work that affects or takes place near covered processes to ensure that the safety of both plant and contractor employees is considered. The standard also mandates written operating procedures; employee training; pre-startup safety reviews; evaluation of mechanical integrity of critical equipment; and written procedures for managing change. PSM specifies a permit system for hot work; investigation of incidents involving releases or near misses of covered chemicals; emergency action plans; compliance audits at least every 3 years; and trade secret protection.

To understand PSM and its requirements, employers and employees need to understand how OSHA uses the term "process" in PSM. Process means any activity involving a highly hazardous chemical including using, storing, manufacturing, handling, or moving such chemicals at the site, or any combination of these activities. For purposes of this definition, any group of vessels that are interconnected, and separate vessels located in a way that could involve a highly hazardous chemical in a potential release, are considered a single process.

PROCESS SAFETY INFORMATION

Employers must complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information, completed under the same schedule required for process hazard analyses, will help the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. Process safety information must include information on the hazards of the highly hazardous chemicals used or produced by the process, information on the technology of the process, and information on the equipment in the process.

Information on the hazards of the highly hazardous chemicals in the process shall consist of at least the following:
• Toxicity,
• Permissible exposure limits,
• Physical data,• Reactivity data,
• Corrosivity data, and
• Thermal and chemical stability data, and hazardous effects of inadvertent mixing of different materials.

Information on the technology of the process must include at least the following:
• A block flow diagram or simplified process flow diagram,
• Process chemistry,
• Maximum intended inventory,
• Safe upper and lower limits for such items as temperatures, pressures, flows or compositions, and
• An evaluation of the consequences of deviations, including those affecting the safety and health of employees.

Where the original technical information no longer exists, such information may be developed in conjunction with the process hazard analysis in sufficient detail to support the analysis.Information on the equipment in the process must include the following:
• Materials of construction,
• Piping and instrument diagrams (P&lDs),
• Electrical classification,
• Relief system design and design basis,
• Ventilation system design,
• Design codes and standards employed,
• Material and energy balances for processes built after May 26, 1992, and
• Safety systems (e.g., interlocks, detection or suppression systems).

The employer shall document that equipment complies with recognized and generally accepted good engineering practices. For existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the employer shall determine and document that the equipment is designed, maintained, inspected, tested, and operated in a safe manner.

The compilation of the above described process safety information provides the basis for identifying and understanding the hazards of a process and is necessary in developing the process hazard analysis and may be necessary for complying with other provisions of PSM such as management of change and incident investigations.

PROCESS HAZARD ANALYSIS

The process hazard analysis is a thorough, orderly, systematic approach for identifying, evaluating, and controlling the hazards of processes involving highly hazardous chemicals. The employer must perform an initial process hazard analysis (hazard evaluation) on all processes covered by this standard. The process hazard analysis methodology selected must be appropriate to the complexity of the process and must identify, evaluate, and control the hazards involved in the process.

First, employers must determine and document the priority order for conducting process hazard analyses based on a rationale that includes such considerations as the extent of the process hazards, the number of potentially affected employees, the age of the process, and the operating history of the process. All process hazard analyses must be updated and revalidated, based on their completion date, at least every 5 years.

The employer must use one or more of the following methods, as appropriate, to determine and evaluate the hazards of the process being analyzed:
• What-if,• Checklist,
• What-lf/checklist,
• Hazard and operability study (HAZOP),
• Failure mode and effects analysis (FMEA),
• Fault tree analysis, or
• An appropriate equivalent methodology.

Whichever method(s) are used, the process hazard analysis must address the following: • The hazards of the process;
• The identification of any previous incident that had a potential for catastrophic consequences in the workplace;
• Engineering and administrative controls applicable to the hazards and their interrelationships, such as appropriate application of detection methodologies to provide early warning of releases. Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors;
• Consequences of failure of engineering and administrative controls;
• Facility siting;
• Human factors; and
• A qualitative evaluation of a range of the possible safety and health effects on employees in the workplace if there is a failure of controls.

OSHA believes that the process hazard analysis is best performed by a team with expertise in engineering and process operations, and that the team should include at least one employee who has experience with and knowledge of the process being evaluated. Also, one member of the team must be knowledgeable in the specific analysis methods being used.

The employer must establish a system to address promptly the team's findings and recommendations; ensure that the recommendations are resolved in a timely manner and that the resolutions are documented; document what actions are to be taken; develop a written schedule of when these actions are to be completed; complete actions as soon as possible; and communicate the actions to operating, maintenance, and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.

At least every 5 years after the completion of the initial process hazard analysis, the process hazard analysis must be updated and revalidated by a team meeting the standard's requirements to ensure that the hazard analysis is consistent with the current process.

Employers must keep on file and make available to OSHA, on request, process hazard analyses and updates or revalidation for each process covered by PSM, as well as the documented resolution of recommendations, for the life of the process.

OPERATING PROCEDURES

The employer must develop and implement written operating procedures, consistent with the process safety information, that provide clear instructions for safely conducting activities involved in each covered process. OSHA believes that tasks and procedures related to the covered process must be appropriate, clear, consistent, and most importantly, well communicated to employees. The procedures must address at least the following elements:
Steps for each operating phase:
• Initial startup;
• Normal operations;
• Temporary operations;
• Emergency shutdown, including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner;
• Emergency operations;
• Normal shutdown; and
• Startup following a turnaround, or after an emergency shutdown.
Operating limits:
• Consequences of deviation, and
• Steps required to correct or avoid deviation.
Safety and health considerations:
• Properties of, and hazards presented by, the chemicals used in the process;
• Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment;
• Control measures to be taken if physical contact or airborne exposure occurs;
• Quality control for raw materials and control of hazardous chemical inventory levels; and
• Any special or unique hazards.
• Safety systems (e.g., interlocks, detection or suppression systems) and their functions.

To ensure that a ready and up-to-date reference is available, and to form a foundation for needed employee training, operating procedures must be readily accessible to employees who work in or maintain a process. The operating procedures must be reviewed as often as necessary to ensure that they reflect current operating practices, including changes in process chemicals, technology, and equipment, and facilities. To guard against outdated or inaccurate operating procedures, the employer must certify annually that these operating procedures are current and accurate.

The employer must develop and implement safe work practices to provide for the control of hazards during work activities such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices must apply both to employees and to contractor employees.

EMPLOYEE PARTICIPATION

Employers must develop a written plan of action to implement the employee participation required by PSM. Under PSM, employers must consult with employees and their representatives on the conduct and development of process hazard analyses and on the development of the other elements of process management, and they must provide to employees and their representatives access to process hazard analyses and to all other information required to be developed by the standard.

TRAINING

Initial Training

OSHA believes that the implementation of an effective training program is one of the most important steps that an employer can take to enhance employee safety. Accordingly, PSM requires that each employee presently involved in operating a process or a newly assigned process must be trained in an overview of the process and in its operating procedures. The training must include emphasis on the specific safety and health hazards of the process, emergency operations including shutdown, and other safe work practices that apply to the employee's job tasks. Those employees already involved in operating a process on the PSM effective date do not necessarily need to be given initial training. Instead, the employer may certify in writing that the employees have the required knowledge, skills, and abilities to safely carry out the duties and responsibilities specified in the operating procedures.

Refresher Training

Refresher training must be provided at least every 3 years, or more often if necessary, to each employee involved in operating a process to ensure that the employee understands and adheres to the current operating procedures of the process. The employer, in consultation with the employees involved in operating the process, must determine the appropriate frequency of refresher training.

Training Documentation

The employer must determine whether each employee operating a process has received and understood the training required by PSM. A record must be kept containing the identity of the employee, the date of training, and how the employer verified that the employee understood the training..

CONTRACTORS

Application

Many categories of contract labor may be present at a jobsite; such workers may actually operate the facility or do only a particular aspect of a job because they have specialized knowledge or skill. Others work only for short periods when there is need for increased staff quickly, such as in turnaround operations. PSM includes special provisions for contractors and their employees to emphasize the importance of everyone taking care that they do nothing to endanger those working nearby who may work for another employer.

PSM, therefore, applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. It does not apply, however, to contractors providing incidental services that do not influence process safety, such as janitorial, food and drink, laundry, delivery, or other supply services.

Employer Responsibilities

When selecting a contractor, the employer must obtain and evaluate information regarding the contract employer's safety performance and programs. The employer also must inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process; explain to contract employers the applicable provisions of the emergency action plan; develop and implement safe work practices to control the presence, entrance, and exit of contract employers and contract employees in covered process areas; evaluate periodically the performance of contract employers in fulfilling their obligations; and maintain a contract employee injury and illness log related to the contractor's work in the process areas.

Contract Employer Responsibilities

The contract employer must:
• Ensure that contract employees are trained in the work practices necessary to perform their job safely;
• Ensure that contract employees are instructed in the known potential fire, explosion, or toxic release hazards related to their job and the process, and in the applicable provisions of the emergency action plan;
• Document that each contract employee has received and understood the training required by the standard by preparing a record that contains the identity of the contract employee, the date of training, and the means used to verify that the employee understood the training;
• Ensure that each contract employee follows the safety rules of the facility including the required safe work practices required in the operating procedures section of the standard; and
• Advise the employer of any unique hazards presented by the contract employer's work.

PRE-STARTUP SAFETY REVIEW

It is important that a safety review takes place before any highly hazardous chemical is introduced into a process. PSM, therefore, requires the employer to perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information. Prior to the introduction of a highly hazardous chemical to a process, the pre-startup safety review must confirm the following:
• Construction and equipment are in accordance with design specifications;
• Safety, operating, maintenance, and emergency procedures are in place and are adequate;
• A process hazard analysis has been performed for new facilities and recommendations have been resolved or implemented before startup, and modified facilities meet the management of change requirements; and
• Training of each employee involved in operating a process has been completed.

MECHANICAL INTEGRITY

OSHA believes it is important to maintain the mechanical integrity of critical process equipment to ensure it is designed and installed correctly and operates properly. PSM mechanical integrity requirements apply to the following equipment:
• Pressure vessels and storage tanks;
• Piping systems (including piping components such as valves);
• Relief and vent systems and devices;
• Emergency shutdown systems;
• Controls (including monitoring devices and sensors, alarms, and interlocks); and
• Pumps.

The employer must establish and implement written procedures to maintain the ongoing integrity of process equipment. Employees involved in maintaining the ongoing integrity of process equipment must be trained in an overview of that process and its hazards and trained in the procedures applicable to the employees's job tasks.

Inspection and testing must be performed on process equipment, using procedures that follow recognized and generally accepted good engineering practices. The frequency of inspections and tests of process equipment must conform with manufacturers' recommendations and good engineering practices, or more frequently if determined to be necessary by prior operating experience. Each inspection and test on process equipment must be documented, identifying the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test.

Equipment deficiencies outside the acceptable limits defined by the process safety information must be corrected before further use. In some cases, it may not be necessary that deficiencies be corrected before further use, as long as deficiencies are corrected in a safe and timely manner, when other necessary steps are taken to ensure safe operation.

In constructing new plants and equipment, the employer must ensure that equipment as it is fabricated is suitable for the process application for which it will be used. Appropriate checks and inspections must be performed to ensure that equipment is installed properly and is consistent with design specifications and the manufacturer's instructions.

The employer also must ensure that maintenance materials, spare parts, and equipment are suitable for the process application for which they will be used.

HOT WORK PERMIT

A permit must be issued for hot work operations conducted on or near a covered process. The permit must document that the fire prevention and protection requirements in OSHA regulations (29 CFR 1926.352) have been implemented prior to beginning the hot work operations; it must indicate the date(s) authorized for hot work; and identify the object on which hot work is to be performed. The permit must be kept on file until completion of the hot work.

MANAGEMENT OF CHANGE

OSHA believes that contemplated changes to a process must be thoroughly evaluated to fully assess their impact on employee safety and health and to determine needed changes to operating procedures. To this end, the standard contains a section on procedures for managing changes to processes. Written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures, and change to facilities that affect a covered process, must be established and implemented. These written procedures must ensure that the following considerations are addressed prior to any change:
• The technical basis for the proposed change,
• Impact of the change on employee safety and health,
• Modifications to operating procedures,
• Necessary time period for the change, and
• Authorization requirements for the proposed change.

Employees who operate a process, and maintenance and contract employees whose job tasks will be affected by a change in the process must be informed of, and trained in, the change prior to startup of the process or startup of the affected part of the process. If a change covered by these procedures results in a change in the required process safety information, such information also must be updated accordingly. If a change covered by these procedures changes the required operating procedures or practices, they also must be updated.

INCIDENT INVESTIGATION

A crucial part of the process safety management program is a thorough investigation of incidents to identify the chain of events and causes so that corrective measures can be developed and implemented. Accordingly, PSM requires the investigation of each incident that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical in the workplace.

Such an incident investigation must be initiated as promptly as possible, but not later than 48 hours following the incident. The investigation must be by a team consisting of at least one person knowledgeable in the process involved, including a contract employee if the incident involved the work of a contractor, and other persons with appropriate knowledge and experience to investigate and analyze the incident thoroughly.

An investigation report must be prepared including at least:
• Date of incident,
• Date investigation began,
• Description of the incident,
• Factors that contributed to the incident, and
• Recommendations resulting from the investigation.

A system must be established to promptly address and resolve the incident report findings and recommendations. Resolutions and corrective actions must be documented and the report reviewed by all affected personnel whose job tasks are relevant to the incident findings (including contract employees when applicable). The employer must keep these incident investigation reports for 5 years.

EMERGENCY PLANNING AND RESPONSE

If, despite the best planning, an incident occurs, it is essential that emergency pre-planning and training make employees aware of, and able to execute, proper actions. For this reason, an emergency action plan for the entire plant must be developed and implemented in accordance with the provisions of other OSHA rules [29 CFR 1926.35(a)]. In addition, the emergency action plan must include procedures for handling small releases of hazardous chemicals. Employers covered under PSM also may be subject to the OSHA hazardous waste and emergency response regulation [29 CFR 1926.65(a), (p), and (q)].

COMPLIANCE AUDITS

To be certain process safety management is effective, employers must certify that they have evaluated compliance with the provisions of PSM at least every 3 years. This will verify that the procedures and practices developed under the standard are adequate and are being followed. The compliance audit must be conducted by at least one person knowledgeable in the process and a report of the findings of the audit must be developed and documented noting deficiencies that have been corrected. The two most recent compliance audit reports must be kept on file.

TRADE SECRETS

Employers must make available all information necessary to comply with PSM to those persons responsible for compiling the process safety information, those developing the process hazard analysis, those responsible for developing the operating procedures, and those performing incident investigations, emergency planning and response, and compliance audits, without regard to the possible trade secret status of such information. Nothing in PSM, however, precludes the employer from requiring those persons to enter into confidentiality agreements not to disclose the information.

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